Reminders for trial

Here are some concepts I keep on a sheet in front of my trial notebook during a trial:

  • BE BRIEF & GET TO THE POINT
  • TALK TO THE JURY – ONE BY ONE
  • stick to the main point – don’t stray
  • Be Calm – Stay calm & confident
  • Be Poised – stop, listen & think – act
  • Be Slow – Pace & timing: [speak slowly]
  • Be Clear – Short & clear [Use analogies]
  • Be Nice – Always professionally
  • WORDS TO REMEMBER:

WAIT
SMILE
LISTEN
FOCUS
ACCEPT
RELAX

Remember: "WHENEVER THERE ARE SEVERAL POSSIBLE EXPLANATIONS, THE SIMPLEST IS USUALLY THE RIGHT ONE" [Occam’s Razor] (Zebra’s vs horses)

Q.Agree that when there is a risk of serious injury or death, there is a duty to take reasonable steps to avoid
the risk and prevent injury?

"Keep calm & do not be afraid – do not lose heart" (Isaiah 7:4)

About Paul Luvera

Plaintiff trial lawyer for 50 years. Past President of the Inner Circle of Advocates & Washington State Trial Lawyers Association. Member American Board of Trial Advocates, American College of Trial Lawyers, International Academy, International Society of Barristers, member of the National Trial Lawyers Hall of Fame & speaker at Spence Trial College
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